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Question Answer Relevant links (if applicable)Additional comments
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NPOs' understanding of risk: What do NPOs understand by the risk of terrorist financing, how do they assess the risk of terrorist financing in the NPO sector and what is their assessment based on? What are the NPOs' views on the Federal Government's sectoral risk analysis?
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Risk mitigation measures: What measures and instruments do NPOs have in place to identify and mitigate risks?
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Government measures: Are the NGOs aware of the measures to combat terrorist financing? Are they considered effective? How does the government support NGOs?
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Regulation: Are the measures taken by the tax authorities considered sufficient? Are the government's measures proportionate and risk-based or are there restrictions on civil society organisations? Scope for action?
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Recommendations to the government: Some questions were aimed directly at the wishes and recommendations of the NPOs to the government. What can the government do better? What is important from the perspective of civil society?
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Problems in payment transactions/de-risking: The FATF sees de-risking as a major problem and refers to its new line of action to prevent unintended negative effects of the FATF recommendations on civil society. Spaces for action. How do NPOs assess the problem and what are possible solutions? Are there any known cases in which NPOs (have to) use alternative payment channels?
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How do you see the risk of NPOs being misused for TF?
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What do the internal risk assessments of NPOs look like? How are they done?
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How was the NGO sector’s involvement in the National Risk Assessment?
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How is your engagement with the banking sector?
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Has one of the NGOs been visited by tax authorities?
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What do you want from authorities? What could/should change?
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